State Motion in Limine Re Neuropsychological Evidence

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PDF State Motion in Limine Re Neuropsychological EvidencePsychiatric Evidence Exclusion
court Court Filing Idaho 4

Named in this document

  • Ashley Jennings Person
  • Bryan Kohberger Person
  • Will Adams Person
Electronically Filed
2/21/2025 4:03 PM

Fourth Judicial District, Ada County Trent Tripple, Clerk of the Court
By: Sara Wright, Deputy Clerk
LATAH COUNTY PROSECUTOR'S OFFICE

WILLIAM W. THOMPSON, JR., ISB No. 2613
PROSECUTING ATTORNEY

ASHLEY S. JENNINGS, ISB No. 8491
SENIOR DEPUTY PROSECUTOR

Latah County Courthouse 522 S. Adams Street, Ste. 211 Moscow, ID 83843
Phone: (208) 883-2246 paservice@latahcountyid.gov
IN THE DISTRICT COURT OF THE FOURTH JUDICIAL DISTRICT OF THE
STATE OF IDAHO, IN AND FOR THE COUNTY OF ADA

STATE OF IDAHO, Case No. CR01-24-31665 Plaintiff,
STATE'S MOTION IN LIMINE

V. RE: NEUROPSYCHOLOGICAL

AND PSYCHIATRIC EVIDENCE

BRYAN C. KOHBERGER,

Defendant.

COMES NOW the State of Idaho, by and through the Latah County Prosecuting Attorney, and respectfully moves the Court for an order in limine prohibiting Defendant from offering testimony regarding neuropsychological evaluation and psychiatric evaluation of the Defendant as summarized in the Defendant's January 23, 2025, “ Supplemental Response to Request for Discovery Regarding Expert Witnesses. ” Specifically, the State objects to the proposed testimony of expert witnesses identified in Defendant's Exhibits D-7 and D-13 appended to Defendant's “ Supplemental Response to Request for Discovery Regarding Expert Witnesses. " In support of this motion, the State respectfully refers the Court to Idaho Code §18-207
STATE'S MOTION IN LIMINE RE: NEUROPSYCHOLOGICAL AND PSYCHIATRIC EVIDENCE 1

which provides that “ mental condition shall not be a defense to any charge of criminal conduct ” except “ expert evidence on the issues of any state of mind which is an element of the offense... ” Idaho Code 18-207 (1) and (3).

In each of the witness summaries (Defendant's Exhibit D-7 and D-13) the Defendant specifically states the “ testimony is not intended to be a mental element defense pursuant to Idaho Code §18-207; but rather this testimony (is) about state of mind as well as factual defense testimony to anticipated testimony elicited by the State. ” As such, this proposed testimony falls outside of the mental condition evidence allowable under Idaho Code §18-207 (3).

RESPECTFULLY SUBMITTED this 21st day of February 2025.

2224 William W. Thompson, Jr.

Prosecuting Attorney
STATE'S MOTION IN LIMINE RE: NEUROPSYCHOLOGICAL AND PSYCHIATRIC EVIDENCE 2

CERTIFICATE OF DELIVERY

I hereby certify that true and correct copies of the STATE'S MOTION IN LIMINE RE:
NEUROPSYCHOLOGICAL AND PSYCHIATRIC EVIDENCE were served on the following in the manner indicated below:
Anne Taylor Mailed Attorney at Law E-filed & Served / E-mailed PO Box 2347 Faxed Coeur D Alene, ID 83816 Hand Delivered Dated this 21st day of February 2025.

STATE'S MOTION IN LIMINE RE: NEUROPSYCHOLOGICAL AND PSYCHIATRIC EVIDENCE 3